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Minutes of the Financial Stability Oversight Council
July 28, 2022
PRESENT:
Janet L. Yellen, Secretary of the Treasury and Chairperson of the Financial Stability Oversight
Council (Council)
Jerome H. Powell, Chair, Board of Governors of the Federal Reserve System (Federal Reserve)
Martin Gruenberg, Acting Chairman, Federal Deposit Insurance Corporation (FDIC)
Gary Gensler, Chair, Securities and Exchange Commission (SEC)
Rostin Behnam, Chairman, Commodity Futures Trading Commission (CFTC)
Rohit Chopra, Director, Consumer Financial Protection Bureau (CFPB)
Sandra L. Thompson, Director, Federal Housing Finance Agency (FHFA)
Michael J. Hsu, Acting Comptroller of the Currency, Office of the Comptroller of the Currency
(OCC)
Todd M. Harper, Chairman, National Credit Union Administration (NCUA)
Thomas E. Workman, Independent Member with Insurance Expertise
James Martin, Acting Director, Office of Financial Research (OFR), Department of the Treasury
(non-voting member)
Steven Seitz, Director, Federal Insurance Office (FIO), Department of the Treasury (non-voting
member)
Charles G. Cooper, Commissioner, Texas Department of Banking (non-voting member)
Elizabeth K. Dwyer, Superintendent of Financial Services, Rhode Island Department of Business
Regulation (non-voting member)
GUESTS:
Department of the Treasury (Treasury)
Nellie Liang, Under Secretary for Domestic Finance
Sandra Lee, Deputy Assistant Secretary for the Council
Laurie Schaffer, Principal Deputy General Counsel
Eric Froman, Assistant General Counsel (Banking and Finance)
Board of Governors of the Federal Reserve System
Michael Barr, Vice Chair for Supervision
Andreas Lehnert, Director, Division of Financial Stability
Federal Deposit Insurance Corporation
James McGraw, Senior Deputy Director, Division of Complex Institution Supervision and
Resolution
Securities and Exchange Commission
Amanda Fischer, Senior Counselor

Commodity Futures Trading Commission
David Gillers, Chief of Staff
Consumer Financial Protection Bureau
Gregg Gelzinis, Advisor to the Director
Federal Housing Finance Agency
Naa Awaa Tagoe, Acting Deputy Director, Division of Housing Mission and Goals
Comptroller of the Currency
Jay Gallagher, Acting Senior Deputy Comptroller for Supervision Risk and Analysis
National Credit Union Administration
Timothy Flynn, Economist, Office of the Chief Economist
Office of the Independent Member with Insurance Expertise
Charles Klingman, Senior Policy Advisor
Federal Reserve Bank of New York
Richard Crump, Vice President, Capital Markets Function
Office of Financial Research
Michael Passante, Chief Counsel
Federal Insurance Office
Philip Goodman, Senior Insurance Regulatory Policy Analyst
Texas Department of Banking
Karen Lawson, Senior Vice President for Policy, Conference of State Bank Supervisors
Rhode Island Department of Business Regulation
Kay Noonan, General Counsel, National Association of Insurance Commissioners
Maryland Office of the Attorney General, Securities Division
Dylan White, Assistant General Counsel, North American Securities Administrators Association
PRESENTERS:
Hedge Fund Working Group Update
• Sandra Lee, Deputy Assistant Secretary for the Council, Treasury
• Ron Alquist, Senior Policy Advisor, Office of the Financial Stability Oversight Council,
Treasury
• Danny Barth, Senior Economist, Division of Financial Stability, Federal Reserve
(available for questions)
• Phillip Monin, Economist, Division of Monetary Affairs, Federal Reserve (available for
questions)
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•
•
•
•

Adam Minson, Lead, Financial Sector Risk, Federal Reserve Bank of New York
(available for questions)
Timothy Husson, Associate Director, Division of Investment Management, SEC
(available for questions)
Ted Berg, Senior Financial Analyst, OFR (available for questions)
Jay Kahn, Senior Economist, OFR (available for questions)

Climate-related Financial Risk Committee Update
• Sandra Lee, Deputy Assistant Secretary for the Council, Treasury
• Sini Matikainen, Policy Advisor, Office of the Financial Stability Oversight Council,
Treasury
• Kaitlin Hildner, Senior Advisor, Division of Research and Statistics, FHFA (available for
questions)
• DJ Purnell, Associate Director, OFR (available for questions)
Digital Assets Report Update
• Sandra Lee, Deputy Assistant Secretary for the Council, Treasury
• Jonathan Rose, Senior Economist, Federal Reserve Bank of Chicago
OFR Bilateral Repurchase Agreement Data Collection
• James Martin, Acting Director, OFR
• Jay Kahn, Senior Economist, OFR
Executive Session
The Chairperson called the executive session of the meeting of the Council to order at
approximately 10:01 A.M. The Council convened by videoconference. The Chairperson first
noted that the meeting was the 100th meeting of the Council, and she thanked Council members
for their contributions. The Chairperson also congratulated Sandra Thompson on her
confirmation as Director of the FHFA, and Michael Barr on his confirmation as Vice Chair for
Supervision at the Federal Reserve. She then outlined the meeting agenda, which had previously
been distributed to the members together with other materials. The agenda for the executive
session included (1) an update on the Council’s Hedge Fund Working Group, (2) an update on
the Council’s staff-level Climate-related Financial Risk Committee, (3) an update on the
development of the Council’s digital assets report, and (4) a presentation on the OFR’s bilateral
repurchase agreement (repo) data collection.
1. Update on Hedge Fund Working Group
The Chairperson turned to the first agenda item, an update on the Council’s Hedge Fund
Working Group, which was reestablished in March 2021. She introduced Sandra Lee, Deputy
Assistant Secretary for the Council at Treasury, and Ron Alquist, Senior Policy Advisor in the
Office of the Financial Stability Oversight Council at Treasury.
Ms. Lee noted that at the Council meeting on February 4, 2022, staff had stated that the Hedge
Fund Working Group would develop an interagency hedge fund risk monitoring framework, to
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expand the Council’s understanding of the potential threats that hedge funds may pose to U.S.
financial stability. She stated that Council member agencies had drawn upon their collective
expertise and resources to develop the framework. She said that through this collaboration, the
Council sought to develop a means to assess hedge fund activities and their implications for
systemic risk.
Mr. Alquist stated that the working group had proposed four workstreams for 2022: (1) develop
an interagency risk monitoring framework to identify financial stability risks related to hedge
funds; (2) consider policy options to mitigate identified risks; (3) coordinate with the InterAgency Working Group on Treasury Market Surveillance (IAWG) regarding Treasury market
resilience; and (4) close data gaps and improve data availability. He noted that his presentation
at this meeting focused on the first workstream, the development of an interagency risk
monitoring framework. He stated that the risk monitoring framework being developed
incorporated a quantitative and qualitative component and drew upon research findings and
analysis from agencies participating in the working group. He described the data sources for the
quantitative risk monitor. He stated that working group participants had also conducted outreach
to industry representatives.
Mr. Alquist stated that the working group found that hedge funds had performed unevenly
through recent geopolitical shocks and elevated market volatility but had not caused significant
disruptions to the U.S. financial system. He stated that since the default of the family office
Archegos Capital Management, bank supervisors’ extensive work related to counterparty credit
risk management revealed material deficiencies which, despite some improvements, still required
corrective action.
Mr. Alquist then discussed recent trends in hedge fund activities, noting that hedge funds’
notional exposures to Treasuries and repo borrowing remained elevated, although they were
reduced from their peak in 2020. He also noted that hedge fund equity exposures had increased
and that prime brokerage borrowing remained high by historical standards. Mr. Alquist stated
that banking and broker-dealer supervisors were continuing to work to address vulnerabilities in
Treasury markets, and that the IAWG was working to improve Treasury market resilience.
Mr. Alquist stated in conclusion that the Hedge Fund Working Group’s risk monitoring
framework was designed to be flexible and account for emerging risks and vulnerabilities. He
noted that the working group planned to implement the interagency risk monitor by the end of
the third quarter of 2022. He stated that the working group expected to provide future briefings
to discuss the risks it identifies using this framework, along with existing regulations and
mitigants.
Council members then had a discussion about the hedge fund risk monitoring framework and
Council member agencies’ efforts to collect and analyze data regarding hedge funds.
2. Update on Climate-related Financial Risk Committee
The Chairperson then introduced the next agenda item, an update on the Council’s Climaterelated Financial Risk Committee (CFRC). She introduced Sandra Lee, Deputy Assistant
Secretary for the Council at Treasury, and Sini Matikainen, Policy Advisor in the Office of the
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Financial Stability Oversight Council at Treasury. She noted that Kaitlin Hildner, Senior
Advisor in the Division of Research and Statistics at FHFA, and DJ Purnell, Associate Director
at the OFR, were available for questions.
Ms. Lee stated that the Council’s 2021 Report on Climate-Related Financial Risk identified
climate change as an emerging threat to U.S. financial stability for the first time and included
over 30 recommendations to financial regulators on how best to identify and address climaterelated risks to the financial system.
Ms. Lee stated that since the publication of the report, the Council and its members had made
progress on these recommendations, including by establishing the new staff-level Climaterelated Financial Risk Committee. She stated that the CFRC, which included representatives of
all 15 Council members, served as an active forum for interagency information-sharing,
coordination, and capacity-building.
Ms. Matikainen stated that the Council’s climate report included recommendations to U.S.
financial regulators in four categories: building capacity; filling climate-related methodological
and data gaps; enhancing climate-related disclosures; and mitigating risks, including through
scenario analysis. She noted that the Council had approved the CFRC charter in December
2021. She stated that the CFRC was meeting regularly to provide a forum to advance the
report’s recommendations. She described the key duties of the CFRC, as set forth in its publicly
available charter, including identifying priority areas for assessing and mitigating climate-related
risks to the financial system and providing updates to the Council at least semiannually.
Ms. Matikainen then provided an overview of the CFRC’s structure. She stated that the CFRC’s
working groups, which included representatives from every Council member, focused on four
areas: data infrastructure, data requirements, risk assessment, and scenario analysis. She noted
that the CFRC met regularly to discuss cross-cutting topics, with the four working groups
performing more targeted work in key priority areas.
Ms. Matikainen stated that Council members had made progress in each of the four categories of
recommendations in the Council climate report. She noted, among other efforts, that all Council
members had assigned staff to work on climate-related financial risk; the OFR had launched its
Climate Data and Analytics Hub pilot with the Federal Reserve; the SEC had proposed rules to
enhance and standardize climate-related disclosures for investors; the OCC and FDIC requested
public comment on a draft statement of principles for climate-related financial risk management
for large banks; and several Council members had expanded their international engagement on
climate-related financial risk.
Ms. Matikainen stated that the climate report recommended that the Council establish a Climaterelated Financial Risk Advisory Committee (CFRAC), which would be the Council’s first
external advisory committee. She stated that the CFRAC was under development and was
expected to encompass a range of external stakeholders to support the CFRC and its working
groups. She stated that staff anticipated that the Council would vote to establish the CFRAC at a
future meeting in 2022.

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Ms. Matikainen concluded by summarizing the next steps for the CFRC, including further work
to advance the recommendations in the Council climate report, continued regular CFRC
meetings, efforts to finalize timelines and deliverables for the CFRC working groups, semiannual
updates by the CFRC to the Council, and contributions to the Council’s 2022 annual report.
Following the presentation, the Chairperson stated that identifying and addressing climaterelated financial risks was a key priority for the Council and noted that the CFRC would play a
central part in this effort.
Council members then had a discussion about efforts on climate-related financial risk at various
member agencies, including risk-management expectations for large banks; regulators’
international engagement; issues in the regulation of insurers; data collections; and public
disclosure requirements.
3. Update on Digital Assets Report
The Chairperson then introduced the next agenda item, an update on the Council report being
prepared in response to the Executive Order on Ensuring Responsible Development of Digital
Assets, which was issued on March 9, 2022. She introduced Sandra Lee, Deputy Assistant
Secretary for the Council at Treasury, and Jonathan Rose, Senior Economist at the Federal
Reserve Bank of Chicago.
Ms. Lee stated that Council member staff had made substantial progress in the development of
the report. She stated that member staff had been collaborating to analyze financial stability
risks and regulations and to understand the turbulence in digital assets markets in 2022.
Mr. Rose stated that the Council had convened a staff-level digital assets working group in April
2022 to prepare the report, and that the group had made progress in outlining financial stability
risks and identifying regulatory gaps posed by various types of digital assets. He noted that the
working group had developed a framework for consideration of these risks organized around
vulnerabilities that amplify shocks to the digital asset market. He also described certain risks
that may be identified in the Council’s report. He concluded by stating that the report would
assess the current regulatory system for digital assets and describe specific regulatory gaps.
Council members then had a discussion about the development of the digital assets report.
4. OFR Bilateral Repo Data Collection
The Chairperson then introduced the next agenda item, a presentation on the OFR’s work to
collect data on non-centrally cleared bilateral repo. The Chairperson noted that the Council’s
Hedge Fund Working Group continued to highlight the lack of visibility into the repo market,
which is one of the primary sources of leverage for hedge funds. She stated that while progress
had been made to improve repo market transparency, such as the OFR’s existing collection of
data on cleared repo, the stresses in March 2020 showed that regulators did not have sufficient
visibility into non-centrally cleared bilateral repo transactions. She noted that at the Council
meeting on February 4, 2022, the OFR announced it would launch a pilot program that would ask
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several financial institutions to share data on these transactions, with the goal of the OFR
publishing a rule to collect this data on an ongoing basis. She then turned to James Martin,
Acting Director of the OFR, and Jay Kahn, Senior Economist at the OFR, for the presentation.
Acting Director Martin stated that repo plays a critical role in lending and securities markets. He
stated that while high-quality data is critical to assess these markets, historically little data was
available. He noted that after the OFR conducted a pilot project in 2015, the OFR adopted a final
rule in 2019 establishing a data collection focused on centrally cleared bilateral repo transactions.
He noted that the OFR had now laid the groundwork for data collection on another sector of the
market.
Mr. Kahn then described four segments of the repo market: centrally cleared triparty repo,
centrally cleared bilateral repo, non-centrally cleared triparty repo, and non-centrally cleared
bilateral repo. He stated that non-centrally cleared bilateral repo transaction volumes are not
known but represent approximately 60 percent of primary dealer reverse repo and 40 percent of
primary dealer repo. He stated that this segment of the repo market lacks transparency, and that
the OFR’s planned data collection was intended to fill this gap.
Mr. Kahn stated that the OFR met with market participants and industry associations earlier in
2022 to discuss this topic. He stated that the OFR found that data systems among dealers are
heterogenous, and he discussed various dealers’ approaches to data collection and storage. He
said that the OFR pilot data collection was intended to give dealers experience in adapting to
transaction-level reporting.
Mr. Kahn stated that the OFR was collecting data from nine pilot program participants over three
reporting days in June 2022, and had received the first day of trading data for all participants. He
stated that the OFR was drafting a notice of proposed rulemaking regarding the data collection.
He noted that the OFR intended to use information learned from the pilot program during the
rulemaking process. He concluded by stating that the OFR was developing an internal structure
to manage the data once the collection is fully implemented.
Council members then asked questions and had a discussion about the importance of the OFR’s
repo data collection.
5. Other Business
Council members then had a discussion about potential topics to address in an upcoming Council
meeting and other Council priorities.
The Chairperson adjourned the executive session of the meeting at approximately 11:17 A.M.
Open Session
The Chairperson called the open session of the meeting of the Council to order at approximately
11:21 A.M. The Chairperson outlined the agenda for the open session, which included (1) an

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update on the Council’s work on climate-related financial risk, and (2) a vote on the minutes of
the Council’s meeting on April 8, 2022.
1. Update on Climate-related Financial Risk
The Chairperson turned to the first agenda item, an update on the Council’s work on climaterelated financial risk. She stated that addressing climate-related financial risk was a key priority
for the Council. She noted that since the Council published its climate report in 2021, the
Council and its members had made significant progress to advance the recommendations set out
in the report. The Chairperson stated that the Council was committed to providing updates to the
public on its efforts to assess and address climate-related financial risks. The Chairperson then
introduced Sandra Lee, Deputy Assistant Secretary for the Council at Treasury, for an update on
efforts by the Council and its members to identify and address climate-related financial risks.
Ms. Lee stated that the Council and its members had been working in close coordination to
advance the recommendations in the Council’s 2021 climate report. She noted that progress had
been made in the areas of capacity-building, disclosure, data, and risk assessment and mitigation.
She stated the Council’s new staff-level interagency committee, the CFRC, was coordinating
these efforts. She noted that the CFRC charter was approved during the Council’s meeting in
December 2021. She stated that the CFRC had representation from all 15 Council members and
began meeting regularly earlier in 2022. Ms. Lee stated that the CFRC served as an active forum
for interagency information-sharing, coordination, and capacity-building. She stated that, given
the known gaps in climate-related financial data, the continuing evolution in methodologies to
assess risk, and the challenges of translating climate data into potential financial impact, the
CFRC enabled Council members to learn from one another on emerging best practices. She
stated that the CFRC would continue the Council’s work to enhance coordination, build capacity,
and advance initiatives necessary to promote the resilience of the financial system to the risks
posed by climate change. Ms. Lee concluded by stating that staff would provide the Council
with ongoing updates about the CFRC’s work to build on and accelerate existing efforts to
address climate-related financial risks and safeguard the financial system.
The Chairperson stated that she welcomed the creation of the CFRC and the work of Council
member agencies to advance the Council’s understanding and cooperation on this topic. She
stated that climate change, in the form of higher temperatures, droughts, wildfires, intensifying
storms, and other climate-related events, was imposing significant costs on the U.S. economy
and the public. She noted that the United States experienced 20 or more separate billion-dollar
weather and climate disasters in each of 2020 and 2021. She stated that when adjusted for
inflation, the costs attributable to the events of these two years exceeded $111 billion and
$152 billion, respectively. She stated that climate change was responsible for economic and also
human costs. She noted that an estimated 80 million homes in the United States are facing
wildfire risk over the next 30 years, including 1.5 million homes that are at extreme risk. She
stated that evidence was emerging in the United States of how climate change is affecting
financial services. She noted as an example that the increasing frequency and severity of such
disasters was leading to higher premiums for homeowners’ insurance, with property in some
parts of the country becoming practically uninsurable and ultimately potentially unsellable.

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The Chairperson stated that the financial and economic costs from climate change were expected
to grow. She stated that these developments underscored the importance of Council members
taking action to expand capacity, improve data and measurement, and enhance disclosure of
climate-related risks, so that investors, corporations, and other financial institutions can make
better-informed decisions, assess the scale of potential vulnerabilities, and make appropriate
adjustments in regulatory and supervisory tools. The Chairperson then invited other members of
the Council to share information on the efforts at their agencies in this area.
Jerome Powell, Chair of the Federal Reserve, stated that the Federal Reserve appreciated the
progress of the Council and member agencies to implement the recommendations of the Council
climate report and to enhance members’ collective understanding of the impact of climate-related
risks on financial institutions and financial stability. He stated that climate-related financial risk
is an important issue that requires close collaboration and investment across Council members,
as they seek to ensure that financial institutions are effectively managing these risks, and to
promote the resiliency of the financial system to these risks in a manner consistent with
members’ supervisory and financial stability mandates.
Chair Powell stated that the Federal Reserve was engaging with external stakeholders, including
large banks, and building its internal capacity to assess the financial risks of climate change,
including through investing in data, research, and analytics. He stated that the Federal Reserve
was working to understand supervised firms’ risk management capabilities and assessing the
materiality of climate-related exposures. He noted that the Federal Reserve was continuing its
work to identify links between climate change and financial stability, including by investigating
how climate change can increase financial sector vulnerabilities and analyzing potential climaterelated amplification channels. He stated that as the Federal Reserve improves its understanding
of these risks, it was incorporating them into its financial stability framework. Chair Powell
stated that the Federal Reserve would continue to contribute to the work of the CFRC and engage
with other Council members to meet the challenges that climate change poses for the U.S.
financial system.
Gary Gensler, Chair of the SEC, provided an update regarding the SEC’s March 2022 proposed
rule to enhance and standardize climate-related disclosures for investors. Chair Gensler noted
that for the last 90 years, U.S. capital markets had relied on a basic bargain under which
investors could choose to decide which risks to take as long as companies provide full, fair, and
truthful disclosures. He stated that the SEC oversees this basic bargain. He noted that the SEC
had updated disclosure requirements over the decades to meet investor needs. He stated that in
the 1960s the SEC began to require the disclosure of certain risk factors to aid investors, and in
the 1970s the SEC began requiring environmental-related disclosures. He stated that the SEC
elaborated on those requirements repeatedly in subsequent years, including in 2010, when the
SEC issued guidance regarding climate-related disclosures. Chair Gensler estimated that
hundreds of issuers were currently disclosing climate-related information, and hundreds of
institutional investors were making decisions based on this information. He stated that the
SEC’s March 2022 proposed rule on climate-related disclosures was an outgrowth of its prior
rulemakings in this area. He stated that the SEC proposal was intended to improve the
consistency, comparability, and decision-usefulness of disclosure provided by public companies

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to investors. He noted that the proposal received over 14,500 comments, available on the SEC
website.
Chair Gensler stated that the SEC had also issued two proposals related to funds and their
advisors. First, he stated that in May 2022, the SEC proposed modernizing the “names rule”
under the Investment Company Act of 1940 to address changes in the fund industry and
compliance practices in the approximately 20 years since the rule was adopted. He said that the
proposal was intended to help ensure that fund names referencing investment goals related to
climate, or other environmental, social, and governance (ESG) factors, align with the funds’
characteristics and investment strategies. Second, he stated that in May 2022, the SEC also
proposed a rule to enhance disclosures by certain investment advisers and investment companies
about ESG investment practices. He noted that the SEC was seeking public comment on both
proposals. He stated that in issuing these proposals, the SEC was focused on ensuring that
statements made by companies to investors are not materially false or misleading. He stated that
this key principle informed the SEC’s climate disclosure proposals. Chair Gensler concluded by
stating that when issuing these and other rulemakings, the SEC was guided by public input,
economic analysis, the laws that Congress has passed, and the courts’ interpretation of those
laws.
Michael Hsu, Acting Comptroller of the Currency, provided observations on the public feedback
on the OCC’s draft principles for climate-related financial risk management for large banks,
which were issued in December 2021. He stated that the draft principles provided a high-level
framework for the safe and sound management of exposures to climate-related financial risks for
large banks. He noted that for purposes of the draft principles, large banks are those with more
than $100 billion in total consolidated assets. He stated that the OCC received responses from
thousands of individuals, as well as financial services trade groups, banks, environmental and
public interest groups, providers of risk models, and governmental bodies. He stated that the
majority of commenters generally supported the draft principles, while some warned of
regulatory overreach. He noted that most commenters who supported the principles also offered
suggestions for changes, reflecting a range of views on the subjects that should be addressed in
the guidance, the level of detail, and the focus on large institutions. He said that numerous
commenters recommended cooperation with other domestic and international regulators. He
stated that a number of financial services trade groups also expressed general support for a
flexible, principles-based approach to risk management in this area.
Acting Comptroller Hsu noted that the OCC also received many detailed responses on the
specific questions posed. He said that many commenters focused on the two interrelated areas of
scenario analysis and data availability. He stated that the draft principles presented scenario
analysis as an important approach for identifying, measuring, and managing climate-related
risks. He noted that the OCC received detailed comments on how banks currently conduct
scenario analysis, how they should conduct this analysis, and the challenges they face. He said
that commenters identified a number of challenges, including a lack of clarity and guidance, the
level of uncertainty regarding future developments, the absence of granularity in currently
available information, the lack of institutional knowledge and expertise, and the general lack of
reliable data and information. Turning to data availability, he stated that the draft principles
noted that sound risk management depends on the availability of relevant, accurate, and timely
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data, while acknowledging that data in this area is rapidly evolving. He said that the OCC asked
for feedback on what specific data, metrics, tools and models banks need to identify, measure,
monitor, and control their climate-related financial risks. He stated that commenters provided
detailed lists of data needs, information on current data sources, and suggestions on how to
obtain critical data. He stated in conclusion that the OCC was evaluating the feedback received
and determining its next steps.
Martin Gruenberg, Acting Chairman of the FDIC, stated that addressing the financial risks that
climate change poses to the safety and soundness of financial institutions and to the stability of
the financial system was a priority for the FDIC. He stated that the FDIC had established an
internal interdivisional working group tasked with assessing the safety and soundness and
financial stability risks of climate change, and was investing in research to better understand the
transmission channels of climate change risk to financial institutions and to the financial system.
He stated that the FDIC had prioritized international engagement through its participation in
Basel Committee on Banking Supervision and Financial Stability Board groups. He noted that
the FDIC had joined the Network of Central Banks and Supervisors for Greening the Financial
System (NGFS) and was participating in the Council’s CFRC. He noted that in March 2022, the
FDIC had requested comment on a draft statement of principles for climate-related financial risk
management for large financial institutions, designed to help institutions make progress toward
addressing key questions as they consider incorporating climate-related financial risks into their
institutions’ risk management framework. He also noted that climate risks disproportionately
impact low- and moderate-income communities and households, which may have fewer
resources to adapt to and address those risks. He stated that in May 2022, the federal banking
regulators issued a proposed rulemaking to modernize the Community Reinvestment Act (CRA),
including proposals to provide CRA credit for investments to promote climate resiliency and
disaster preparedness in low- and moderate-income communities. He noted that the agencies
were accepting public comments on the proposal.
Rostin Behnam, Chairman of the CFTC, provided an update on the CFTC’s efforts regarding
climate-related financial risk. He stated that the CFTC was focused on climate-related risk
management, anticipating that firms and individuals would increasingly turn to the derivatives
markets to manage and mitigate climate change-induced physical and transmission risks. He
noted that in March 2021, the CFTC created the Climate Risk Unit (CRU) to leverage the
agency’s resources and expertise to better understand the role of derivatives in both pricing and
mitigating climate-related risk and also support the orderly transmission to a net-zero economy
through market-based initiatives. He said that during its initial 12 months, the CRU focused on
engaging with stakeholders to explore opportunities for public-private partnerships.
Chairman Behnam stated that the CRU hosted an all-day voluntary carbon market convening at
the CFTC on June 2, 2022. He stated that the convening included panelists from voluntary
carbon markets and discussed carbon offset standards and quality initiatives; the trading
ecosystem for carbon offsets, which are the underlying commodities for several regulated futures
products; and the participants’ recommendations for the CFTC. He stated that to support a
whole-of-government approach to climate change, the convening included representatives from
the White House’s Office of Science and Technology Policy and the Departments of the

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Treasury, State, Transportation, and Agriculture to discuss their policy initiatives for carbon
offsets.
Chairman Behnam noted that in June 2022, the CFTC also issued a request for information (RFI)
on climate-related financial risk. He said that the RFI was seeking feedback on climate-related
financial risk as it may pertain to the derivatives markets, underlying commodity markets,
registered entities, registrants, and other market participants. He stated that the RFI also
requested input on data, scenario analysis, stress testing, risk management, disclosure, product
innovation, voluntary carbon markets, digital assets, greenwashing, financially vulnerable
communities, and public-private partnerships and engagement. He said that the CFTC may use
this information to issue new or amend existing guidance, interpretations, policy statements, and
regulations, among other potential actions. He stated that the CFTC was focused on ensuring
that market participants are equipped to manage their risks from increasingly severe and frequent
weather events as well as the transition to a net-zero, low carbon economy. He noted in
conclusion that the CFTC would solicit public comment on the RFI until October 7, 2022.
Sandra Thompson, Director of the FHFA, stated that the FHFA and its regulated entities had an
important role to play in addressing issues related to climate change. She stated that much of the
FHFA’s work in the housing sector focused on the impact of events such as natural disasters,
floods, wildfires, and hurricanes on the residential and multifamily mortgage market. She stated
that the FHFA, in its supervisory capacity, had been working to ensure that its regulated entities
account for these risks. She stated that in 2021, the FHFA had issued a statement affirming that
the FHFA was committed to making tangible progress on addressing climate change and its
consequences. She said the statement also noted that the FHFA’s regulated entities should
identify climate change as a priority concern while actively considering its effects in their
decision-making. She noted that in January 2022, the FHFA established an internal climate
change and ESG steering committee. She stated that during 2022, Fannie Mae and Freddie Mac
had worked under the guidance of FHFA to enhance their climate risk frameworks and
governance and to consider the effects of climate-related financial risk on vulnerable
communities.
Director Thompson stated that in May 2022, the FHFA became a member of the NGFS. She
stated that FHFA was an active participant in this organization’s working groups, and also
participated in the Council’s CFRC and its working groups. She also noted that the FHFA was
participating in the Financial Literacy and Education Commission and contributing to its
upcoming report on the effects of climate change, particularly regarding the impacts on low- and
moderate-income and vulnerable communities. She stated in conclusion that the FHFA was
focused on addressing the threat of climate change to preserve the safety and soundness and
stability of the housing finance system.
Steven Seitz, Director of FIO, stated that assessing climate-related financial risk in the insurance
sector was a top priority for FIO. He stated that the insurance sector can play an important role
in combating climate change and in reducing financial losses from climate-related events. He
noted that the availability of insurance is a critical component in the functioning of the housing
and banking sectors. He then highlighted three efforts FIO was undertaking. First, he said that
FIO intended to publish a report by the end of 2022 assessing climate-related issues and gaps in
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the regulation and supervision of insurers, including their potential effects on U.S. financial
stability. He noted that some state insurance regulators were taking steps in this area and said
that FIO would continue to monitor and assess those developments. Second, he stated that FIO
was conducting quantitative analysis in two areas of climate-related financial risk: the potential
transition risk to insurer asset portfolios, and the physical risks of insurers’ climate-related
underwriting exposures, focusing on homeowners’ insurance and particularly on at-risk markets.
He noted that as part of this analysis, FIO would consider how climate change was impacting
underserved communities that are often most affected by, and often least able to respond to,
climate-related events. He stated that such analyses were dependent upon the availability of
relevant, reliable, and granular data. He stated that FIO was continuing to assess the use of its
data-collection and data-dissemination authorities to help fill potential data gaps. Third, he
stated that FIO continued to engage with stakeholders and colleagues domestically and
intentionally, including federal and state partners. He stated that FIO was engaging with the
Intentional Association of Insurance Supervisors and the Sustainable Insurance Forum and noted
that in 2022 FIO joined the NGFS.
James Martin, Acting Director of the OFR, stated that identifying risks to financial stability from
climate change was a priority for both the Council and the OFR. He noted that climate risk is not
easily defined and that its potential risk to the financial system is difficult to model and to
forecast. He stated that to accurately assess this risk, financial regulators would need to combine
and analyze climate and financial data. He said that this requires high-powered computing to
ingest large, often complex data sets, as well as advanced statistical software to merge these data
to create new vantage points. He stated that the OFR was uniquely positioned to provide these
resources to the Council. He said that to test the OFR’s capabilities to open its analytic
environment to analysts and researchers outside of the OFR, it had partnered with the Federal
Reserve to develop the Climate Data and Analytics Hub, which could feature both climate data
and analytic tools. He said that the data hub provided certain staff from the OFR and the Federal
Reserve System access to climate data and offered the tools needed to merge this data with
financial data. He said that the data hub also enabled users to collaborate on their research and
share their findings. He stated that this project demonstrated two ways the OFR can support the
Council: by enabling Council members to use the OFR’s expertise in data onboarding and by
providing access to the OFR’s analytical environment for greater insight into financial stability
risk. He stated that the OFR was working to expand access to the data hub to other Council
members.
Following these remarks, the Chairperson stated that the challenges in the area of climate-related
financial risk were significant and would require the Council’s collective efforts. She noted that
while the Council had made progress in identifying and addressing these risks, the Council
would continue to work on this issue and that it would remain a Council priority.
2. Resolution Approving the Minutes of the Meeting Held on April 8, 2022
BE IT RESOLVED, by the Financial Stability Oversight Council (the “Council”), that the
minutes attached hereto of the meeting held on April 8, 2022 of the Council are hereby
approved.

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The Chairperson asked for a motion to approve the resolution, which was made and seconded.
The Council approved the resolution by unanimous vote.
The Chairperson adjourned the meeting at approximately 11:51 A.M.

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